Download a copy of the submission here or ready the submission online below.

​27/02/2024
 
Department of Infrastructure, Transport, Regional
Development, Communications and the Arts
GPO Box 2154
Canberra ACT 2601
 
 
Australian New Vehicle Efficiency Standard Submission
 
To whom it may concern
 
Thank you for the opportunity to provide input to the Australian New Vehicle Efficiency Standard (NVES) and taking the time to consider our submission.
 
The Clean Energy Association of Newcastle and Surrounds (CLEANaS) strongly supports the implementation of an aggressive Australian New Vehicle Emission Standard (Option C: Fast start).  Option C catches up with US and European emission targets, makes the Australian vehicle market highly appealing for low- and zero-emissions vehicles, maximises savings to the consumer, and accelerates and maximises the reduction of carbon emissions. An effective and strong NVES aligns with the vision and goals of CLEANaS.
 
However, due to the size and increasing nature of transport emissions in Australia, the NVES alone, whether through the government preferred Option B or Option C, will be insufficient to tackle this difficult problem. Additional policies and measures are necessary.  These should include:

• Removal of Parallel Import Restrictions,
• Policies and measures to curb increased use of cars and kms travelled,
• Policies and measures to curb increased sale of larger cars, and
• Regulation to ban the import of HFC-charged automotive air conditioners.

 
CLEANaS is the Clean Energy Association of Newcastle and Surrounds, a not-for-profit association formed in 2012 by a group of locals passionate about clean energy.[1] CLEANaS is dedicated to driving the uptake of clean energy so that our region can transition from its current dependency on fossil fuels to a more competitive and sustainable local economy. We achieve this by working with our partners to demonstrate profitable community-led and community-owned clean energy projects; raise the profile of clean energy in the local economy through education and awareness raising; and by improving access to financing mechanisms and affordable technologies so that investment and activity grow. Our initiatives must deliver a win-win for local community investors, local enterprise and, of course, our environment.
 
The government is responsible for the environment, the health and wellbeing of its citizens, and the financial security of the nation. As we see the impact of increased carbon emissions, we also find evidence of the deleterious impact on Australian native wildlife, the Australian people and the wealth of the nation.  There is only 3 years left at present emission rates of the 2013-2050 emission budget to stay below 1.5°C with Australia having exceeded its carbon budget for 2050 by 2027. By 2055 Australia will experience economic losses on par with covid, getting worse every single year due to unchecked climate change.3
 
The IPCC stated that global emissions need to reach net zero by 2050 to be consistent to limiting warming to 1.5 °C.14 However, last year Australia’s emissions increased by 0.8% (3.6 Mt CO2-e), fueled primarily by a 7.8% (7.1 Mt Co2-e) increase in transport emissions.14
In 2020 Australia emitted 1.1% of world greenhouse gas emissions. This made Australia the world’s 16th biggest emitter of greenhouse gas pollution, despite having just 0.33% of world population.[2]  On a per capita basis. Australian emissions are the highest in the OECD and among the highest in the world. The only countries with higher per capita emissions than Australia are smaller petro-states like Kuwait, Qatar and UAE and some Small Island Developing States. [3] [4] [5]
 
Climate Change ImpactsThe impacts of climate change on the environment are significant and severe. The present scientific consensus is that the earth's climate is warming due to human activity, and the negative impacts of increased greenhouse gas emissions are measurable globally and nationally.[6]
 
Australia’s climate has warmed on average by 1.47 ± 0.24 °C since national records began in 1910, which has led to an increase in the frequency of extreme heat events.[7] The Bureau of Meteorology and CSIRO reported that there has been an increase in extreme fire weather, and in the length of the fire season, across large parts of the country since the 1950s, as evidenced by the catastrophic bushfires in the summer of 2019/2020.  They also noted changes in rainfall, with decreases in the southeast and southwest of Australia as shown by the devastating drought in 2019.  Oceans around Australia they stated are acidifying and have warmed by about 1°C since 1910 bringing longer and more frequent marine heatwaves.  In the past 5 years there have been three major mass-bleaching events at the Great Barrier Reef resulting from these marine heatwaves, and resulting in the destruction of over half of the reef’s corals.[8]  The Great Barrier Reef has an economic, social and iconic asset value estimated at $56 billion, contributes around $6.4 billion annually to the Australian economy and supports over 64,000 jobs.[9]  Sea levels are also rising around Australia, increasing the risk of coastal inundation and damage to infrastructure and communities.6
Economic risksDeloitte Access Economics noted that some of the most significant risks to Australia’s economic growth trajectory are from the physical risks associated with a changing climate and the unplanned economic transition risk from the world’s response to this changing climate.[10]
Their analysis showed that the Australian industries hardest hit by the Covid 19 pandemic would also be the most vulnerable to the effects of a warming world and climate change. Australia’s agriculture, construction, manufacturing, tourism related industries and mining sectors all featured consistently in the top industries exposed to the risks of covid, climate change and the unplanned economic transition as the world responds.  Deloitte Access Economics estimated that by 2055 Australia will experience economic losses on par with Covid 19.10
The government is responsible for the environment, the health and wellbeing of its citizens, and the financial security of the nation. As we see the impact of increased carbon emissions, we also find evidence of the deleterious impact on Australian native wildlife, the Australian people and the wealth of the nation. 
 
Net Zero Emissions by 2050The IPCC stated that global emissions need to reach net zero by 2050 to be consistent to limiting warming to 1.5 °C.14  Modelling has shown that moving towards a net zero emissions economy would unlock financial prospects in sectors including manufacturing and renewables triggering a $63 billion investment boom.[11]  Deloitte Access Economics estimates such a new growth recovery could grow Australia’s economy by $680 billion (present value terms) and increase GDP by 2.6% in 2070 – adding over 250,000 jobs to the Australian economy by 2070.10 
 
The Australian Government has now committed to developing a 2050 Net Zero plan and 2035 emission reduction targets consistent with Australia’s international and domestic commitments.[12] 
 
Emission goalsTo address the issue of dangerous climate change, Australia, along with 196 other parties, is a signatory to the Paris Agreement, which entered into force on 4 November 2016. The Paris Agreement aims to strengthen the global response to the threat of climate change, by:
Holding the increase in the global average temperature to well below 2°C above pre-industrial levels and pursuing efforts to limit the temperature increase to 1.5°C above pre-industrial levels, recognising that this would significantly reduce the risks and impacts of climate change.[13]
Australia has a target to achieve net zero emissions by 2050. Furthermore, in 2022, The Australian Government increased the ambition of its 2030 target in 2022, committing in legislation to reduce greenhouse gas emissions 43% below 2005 levels by 2030[14].
 
Australia’s current emissions and trendsAustralia’s emissions for the year to June 2023 have declined by 24.5% since 2005 primarily due to the “continuing shift in the generation of electricity from coal towards renewable fuel sources”.  At the current rate of decline, emissions will have reduced by approximately 38% by 2030 missing the legislated target by approximately 5%.15
 
Australia’s emissions for the year to June 2023 were approximately 465.2 Mt CO2-e, which is an increase of 0.8% (3.6 Mt CO2-e). This was fueled primarily by a 7.8% (7.1 Mt Co2-e) increase in transport emissions.15
 
The transport sector is the third highest emission sector after electricity and stationary energy with 21.1% of Australia’s emissions. In the year to June 2023, transport accounted for 21.1% of Australia’s national GHG inventory which represents 98.0 Mt CO2-e[15].  Road transport is close to 85% of those emissions[16]. Cars and Light commercial vehicles (LCVs) alone contribute over 60% of Australia’s transport emissions and around 13% of Australia’s total greenhouse gas emissions.
 
Whereas emissions from the electricity sector continue to go down as renewable energy uptake continues, emissions from the transport sector are trending upwards. Transport emissions have increased 19.5% (16.0 Mt CO2-e) since June 2005, despite recent volatility due to the impacts of the COVID pandemic.  Over the year to June 2023 GHG emissions increased by 7.8% (7.1 Mt CO2-e) in actual terms, compared with the previous year.15  Similarly, transport emissions from cars and LCVs grew by 5.6% in the same period, with an long term trend of an estimated 1% growth in emissions each year.16
 
Australia needs real and rapid reductions in CO2 emissions from the transport sector. The Australian government is at risk of not achieving its legislated target to reduce greenhouse gas emissions 43% below 2005 levels by 2030 due to the continued increase in emissions in the transport sector. Urgent action is required to address this issue.
 
Deliver steep reductions earlyEarly and deep emission reductions are essential in meeting the agreed temperature goal of holding the increase in the global average temperature to well below 2°C above pre-industrial levels and pursuing efforts to limit the temperature increase to 1.5°C above pre-industrial levels.13 Moving fast on emission reduction in sectors where technologies are advanced (such as electricity generation and transport) allows more time to deal with sectors that are harder to decarbonise whilst still meeting the ultimate temperature goal. This needs to be considered with policies and measures to reduce Transport emissions.51
 
Australian car emissions intensityAustralian cars produce up to 40% more carbon dioxide than their European counterparts due to high polluting and inefficient fleet[17].  In 2021, CO2 emissions of Australian passenger vehicles were found to be 53% and LCV’s 32% higher than the average for other major markets (China, Japan, US and EU).50
 
The Carbon Dioxide Emissions Intensity for New Australian Light Vehicles Report for 2021 showed Australia falling further behind other countries. Of all new passenger cars sold in Australia that year, 45% had an emissions intensity of 160 g/km or less, compared with 90% of all new cars sold in Europe[18].  The National Transport Commission noted that if all cars sold in 2021 were ‘best in class’ for emissions, Australia’s total 2021 emissions for new vehicles would have reduced by 91% for passenger vehicles and small SUVs and 47% larger SUVs and utes.18
 
Analysis of Options for NVES policy settings 
NVES Objective and principlesThe Government’s key objective of the NVES is to reduce CO2 emissions from new cars to support the achievement of the Government’s legislated 2030 emissions reduction targets.[19]  An NVES is a cost-effective way to facilitate the transition of the Australian vehicle fleet to low- and zero-emissions, to promote higher energy efficiency, lower fuel consumption and running costs, and to reduce the dependence on fossil fuels.50
 
The NVES Impact Analysis provided 3 possible policy options, Option A - slow start, Option B - fast but flexible and Option C - fast start, with Option B the documented preferred option.
In the impact analysis, a number of principles were proposed to assist, together with a cost-benefit analysis, in analysing the merits of these proposed options.  These design principles are: Effective, Equitable, Simple and Transparent, Credible and Robust, and Enabling.  Although these are sometimes referred to as objectives in the impact analysis which is confusing.  It is unclear what the relative ranking/weight of the principles are and whether any are mandatory, only that they are “adequately addressed”.  In comparing options the principles of Equitable and Enabling appear conflated.
 
Based on current transport emissions for Cars and LCVs and the rate that transport emissions are increasing, the proportion of emissions abated from the NVES by 2030 for each option would be:  Option A: 0.2%, Option B: 5.3%, and Option C: 6.9%.15   Therefore, additional policies and measures will need to be taken to ensure the Government’s legislated 2030 emissions reduction targets are met for the Transport sector.
 
Option A does not achieve Government’s key objectiveAs noted in the impact analysis and above, Option A generates negligible abatement and does not support achievement of the Government’s legislated 2030 emissions reduction targets.  As Option A - slow start does not achieve the Government’s key objective of the NVES to reduce CO2 emissions from new cars to support the achievement of the Government’s legislated 2030 emissions reduction targets it should be discarded.
 
Comparing Option B and Option C financial benefitsThe financial benefits of Option B - fast but flexible and Option C - fast start appear comparable with Option C having a greater net benefit but slightly lower benefits cost ratio to 2050.  It would have been preferable to also have the figures to 2030 in line with the Governments legislated targets.  The figures provided in the report have to be taken on face value as there is insufficient information to determine how they are calculated.
 
It is important to remember the complementary health benefits from replacing high-emission cars that are often also highly-polluting cars with low-emissions low-polluting cars.  The current transport sector is brimming with highly-polluting cars that are increasing transport emissions and contributing to poor air quality. University of Melbourne research has found that air pollution from cars, trucks and buses can cause up to 11,100 deaths each year.53
 
Other potential benefits that may change the overall financial benefits of these two options are included further below.
 
Availability of affordable new vehicles will increase not decreaseIn assessing options versus stated design principles, under the principle “Enabling:vehicles with the best emissions and safety technology to be available to Australians”, the impact analysis stated that under Option C there would be “Potential reduced access to affordable new vehicles, partially offset by greater availability of relatively affordable low and zero emissions vehicles.”  There is little to support the assertion of reduced access to affordable new vehicles.
 
Choice of vehicles will increase with an NVESImplementing an effective NVES will increase the diversity / choice of vehicles available in Australia.  An NVES will create an incentive to bring more efficient and electric models to
market.[20]  Car manufacturers in managing their fleet emissions, will literally need to provide greater choice to the market rather than less.[21] IEA noted that stringent NVES’s have promoted EV adoption in most leading EV markets and “should be adopted by all countries seeking to hasten the transition to electromobility.”[22]
 
Prices of cars will not increaseModelling indicates the NVES will increase the cost of ICE vehicles by a marginal 0.3% per annum due to the adoption of the latest technology. This is no evidence that this has actually led to real-world increases in end user prices for ICE vehicles in other countries. Furthermore, modelling indicated the NVES would lead to a decrease EV prices by 2.8% per annum.[23]
 
Implementation of changes for manufacturers should be straightforwardAustralia has been clear about its intention to introduce an NVES for a number of years, so no big surprises.  Both Option B and Option C allow manufacturers 2 years grace period before stringent limits are imposed.
 
Car manufacturers have implemented processes and procedures to manage Vehicle Efficiency Standards across more than 85% of their global markets including the European Union, USA, Canada, Brazil, China, South Korea, Mexico, and right-hand drive markets of India, Japan, United Kingdom and New Zealand.[24]  Australia is a very late comer to this field and existing processes and procedures can be readily adapted by manufacturers to the Australian market.
 
Furthermore, using known fuel-saving strategies, manufacturers can make existing vehicle models comply with emissions standards while saving consumers money and dramatically reducing fuel consumption. Research indicates that for ICE vehicles an NVES can be addressed based upon improving existing ICE vehicle models.[25]
 
Why comparing to US standards is not a good thingThe US standard (of which the NVES is compared) does not appear stringent enough. Fuel efficiency gains have stagnated over the last 9 years, with only an approximate 1.2% average improvement in fuel efficiency per annum.  At this rate the US will miss their 2026 standards target.[26] Following US targets may set Australia up for failure.
 
The European Union, UK and New Zealand have stricter standards than the US.  Stronger targets will deliver greater financial benefits and greater greenhouse gas emissions abatement.  Australian policymakers should adopt standards that align with leading markets and with world's best practice and adopt a standard in line with the strongest standard, the European Standard.  Option B – fast but flexible falls short of what is being done in Europe.50 Option C - fast start is the globally competitive case that catches up with the European Standard in 2029 and should be adopted.
 
Penalty rates should be consistent with other countriesPenalties are levied against suppliers who fail to meet the CO2 target.  These should be consistent with other major countries. Penalties need to be sufficient to impact the profitability of the supplier. Too small and manufacturers will ignore the fines and not make the necessary changes to reduce emissions. Given that per capita incomes between the EU and Australia are similar, there seems no reason to adopt a lower penalty rate in Australia than in the EU. Penalties may also need revision to maintain their deterrence value relative to the trading price of credits. Option C penalty rate is closest to EU and UK standards.[27] [28] [29]
 
WLTP testing adoptedThe official Australian test protocol New European Driving Cycle (NEDC) is outdated and increasingly underestimates on-road emissions. It provides an unrealistic and skewed picture, undermining effective emission reduction. Previous checking has revealed emissions averaged around 25% and up to 40% higher than claimed.28 50  Australian passenger vehicles emissions were found to be underestimated by 46% and LCV’s by 29% for 2021.  Where NEDC continues to be used, these increasing gaps diminishes the effectiveness of an NVES and other measures to reduce transport emissions. Due to this widening gap between NEDC and real-world emissions, the European Union replaced the NEDC test procedure with the Worldwide Harmonized Light-vehicles Test Procedure (WLTP) in 2017.50
 
Real-world testing is critical. It’s vital to measure real-world fuel efficiency and emissions of new vehicles through WLTP and to make this information public to ensure standards are achieving their goals. The standards should also include on-board fuel consumption
monitoring to monitor the real-world fuel efficiency and emissions of new vehicles. To be credible with Australian distributors and consumers, the NVES must replace Australia’s obsolete emissions testing scheme with real-world testing of emissions utilising WLTP as global best practice as soon as possible.49  Monitoring and real-world testing is critical to ensure NVES standards are being met and on track.50
 
Why Option C over government preferred Option BCLEANaS supports Option C over the government preferred Option B.  Option B is very similar to Option C, obtaining a high benefit, and strong positive benefits cost ratio. However, benefits to consumers are 19% higher for Option C. The exclusion of technology credits in Options B and C provides transparency, reduces complexity and avoidance of potential dilution of the NVES. Option B also looks to achieve a large abatement supporting the Government’s legislated 2030 emissions reduction targets.
 
The continued increase in Transport emissions, of which Cars and LCVs form a significant proportion, pose a significant impediment to the achievement of Australia’s commitments under the Paris Agreement and legislated 2030 emissions reduction targets. The NVES alone (either Option B or Option C) will not address this increase in emissions and additional policies and measures will be required. Recent research indicates that to keep up with the pace of technological advancement and decarbonization in other major markets and developed countries, Australian policymakers should consider adopting a stringent, mandatory NVES alongside additional policies.50
 
With a more ambitious headline CO2 target, Option C delivers steep reductions in emissions early and has over 30% additional emission abatement than Option B by 2030.  Reducing emissions early allows more time to deal with sectors that are harder to decarbonise, whilst still meeting Australia’s commitments.
 
Due to transport emissions going in the wrong direction and diluting the gains made in other sectors, where possible emissions reduction abatement from transport policies such as the NVES should happen early and be maximised to ensure any chance of achieving Australia’s commitments under the Paris Agreement and Australia’s legislated 2030 emissions reduction targets.  Therefore Option C is the appropriate choice.
 
Addressing documented risks of Option CVehicle manufacturers will be able to readily adapt existing processes and procedures to the Australian market already used to manage Vehicle Efficiency Standards in the majority of their world markets to “adapt the technology offerings and vehicle supply to Australian consumers” (see above).
 
The impact analysis found that the consumers in rural, regional and remote areas would benefit more financially from the NVES than those in major cities.
 
The justification of weaker standards by evoking the purported needs of certain groups and populations such as farmers and people in regional areas needs to stop.  Farmers should not be stereotyped as they are often keen to be involved in the transition to low emission vehicles and EVs[30] [31] [32] [33].  Jake Whitehead, the head of policy at the Electric Vehicle Council stated that farmers don’t want to pay more for fuel, be dependent on foreign oil, or cause more pollution, and noted that where there are specific issues that make it difficult for some groups to capture benefits of an NVES, the issues should be addressed up front and not use these groups as a shield to push for weaker standards.47
 
 
Other NVES Benefits / Savings 
Fuel SecurityLiquid fuel security is a serious economic and national security issue for Australia. Australia is currently reliant on imports for around 91% for fuel consumption of which 73% are transport fuels including 54% for road transport.  Australia’s transport fuels are highly vulnerable to international prices and supply chains as shown by the Ukraine War and instability in the middle east.34
 
Furthermore, Australia is currently in breach of the IEA stockholding obligation to maintain emergency fuel reserves equivalent to at least 90 days of net oil imports with only 68 days of liquid fuel in reserve. Dependency on imported liquid fuel and lack of reserves makes Australia ill-prepared to deal with a disruption to supply, particularly with the heightened geopolitical risks the nation currently faces.34
 
Improving fuel efficiency and diversifying Australia’s energy mix would increase energy security by reducing overall demand for imported oil and decreasing the potential impact of oil supply chain disruptions.34
 
Under Options B and C, the demand for imported oil would decrease each year as the Australian car fleet was progressively replaced by fuel efficient ICE vehicles, hybrids and EV’s with demand dropping faster with Option C than Option B.  With 25% of the passenger fleet EV’s, 8% of total imports would not be needed (oil displacement impact), with 50%, that would increase to 16%.[34]
 
Trade ImbalanceIn FY 2021-2022, Australia’s top import was Refined Petroleum, with $39.8 Billion expended that year.  Together with imports of $8.3 Billion in Crude Petroleum, oil imports contribute significantly to Australia’s trade balance each year.[35]
 
Coal and Natural Gas exports ($113.8 Billion and $70.6 Billion respectively for FY 2021-2022) are collectively the top export for Australia.35  As demand for fossil fuels decreases overseas as the reliance on fossil fuels diminishes, Australia’s trade balance is expected to worsen impacting on Australia’s current account balance with Australia’s current account deficit expected to grow.  Without a drop in imported oil over this period the effect on the trade balance and current account deficit would be exacerbated.  As noted above, under Options B and C, the demand for imported oil would decrease each year as the Australian car fleet was progressively replaced by fuel efficient ICE vehicles, hybrids and EV’s with demand dropping faster with Option C than Option B, buffering the effects of a potential trade deficit and current account deficit as the world decreases its reliance on fossil fuels.
 
 
What the NVES does not coverThe NVES addresses a cap on emissions intensity but there is no cap on actual emissions. The effectiveness of this policy in reducing emissions are diminished by:

• Manufacturers selling more cars,
• Manufacturers selling larger cars, and
• People driving more kilometres in cars.[36]

 
Curb increased use of carsThe total kms driven each year in Australia increases by approximately 2%16. This directly leads to increased transport emissions that have outpaced improvements in fuel efficiency. The benefits of the NVES will be degraded by this increased use of road transport.  More efficient demand management can reduce transport emissions by changing the way people are moved, and reducing the need for movement while maintaining living standards.37 These changes improve the emissions intensity of travel or reduce transport demand. Passenger mode shift - changing passengers from higher to lower emissions modes, e.g. from road to public transport, walking, cycling and rail lead to reduced emissions.  Urban and transport planning can help reduce travel requirements and encourage mode shift to active and public transport; for example, by locating employment and schools close to communities that need them, or creating urban environments that encourage walking rather than driving.[37] 
 
Research has identified numerous measures and policy instruments that have reduced car use in European cities that should be applicable in Australian cities where 85% of Australians live.  These include: Congestion Charges, Parking & Traffic Control, Limited Traffic Zones, Workplace Parking Charges, and Mobility Services for Commuters.[38] [39]
 
“We don’t need to see more cars on the road, but better planning to get Australians out of their cars as the primary means of travel”.  Doctors for the Environment Australia’s Executive Director and GP, Dr Kate Wylie stated that:
 
Active transport such as walking, cycling, or public transport are needed and will save time, money and lives. A shift away from private car use will give more rapid and deeper reductions in transport pollution while improving physical health, make our cities better places to be, and reduce congestion.[40]
 
Curb increased sale of larger carsThere is a continued long-term shift towards Sport Utility Vehicles (SUVs) in major automotive markets across most of the world. Between 2010 and 2019, sales-weighted average new light-duty vehicles became 6.2% heavier, 20% more powerful and had a 7% larger footprint, with a key cause of this trend being a shift from cars (sedans) to SUVs and light trucks.  SUVs’ global share of new light-duty vehicle sales rose from 20% in 2010 to 44% in 2019.  Even in markets with high SUV sales, such as the United States, SUVs continue to claim a larger share of the market. Australia is little different to the US and Europe with SUV purchases growing at over 7% per annum.  In 2023, 55.8% of all car sales were SUVs.[41] This has underpinned increases in larger, heavier, and more powerful vehicles, which has led to increased oil consumption, direct CO2 emissions and vehicle weight, size and power. On average, SUVs consume around 20% more oil than an average medium-size car. The combustion-related CO2 emissions of SUVs increased by nearly 70 million tonnes in 2022. In Europe, the net effect of heavier, more powerful vehicles and of small increases in hybrid electric vehicle and electric vehicle sales shares was a 5.4% increase in fuel consumption between 2017 and 2019. Without the shift towards SUVs, energy use per km for combustion engine vehicles could have fallen at an average annual rate that is 30% higher than it did from 2010 to 2022.[42] [43]
 
In Australia, the number of light commercial vehicles (category mostly representing utes) continues to increase at a rate of around 5% each year.16  In 2023, 22.5% of all car sales were utes. This is despite there being more than 1.5 times as many utes as technical and trade workers.41
 
As seen in Europe and the US, vehicle efficiency standards alone are insufficient to address the erosion of reduction of CO2 emissions gained through vehicle efficiency standards by the adoption of larger vehicles such as SUV’s.
 
The “breakpoints” in the NVES policy Options B and C work to address manufacturers simply increasing the weight of the vehicle to allow for higher emissions per km, and Option C further limits this ability through a reduced slope of the fleet limit curve (less increased emissions per km allowed for each kg of increased weight than Option B).  However, further disincentives are needed to reduce emissions.  The Climate Council recommends curtailing tax policies that incentivise the purchase of larger, heavier, high emission vehicles such as the Fringe Benefits Tax exemption and the recently ended Instant Asset Write-Off.[44] Furthermore, IEA Global Fuel Economy Initiative details numerous policy options and recommendations, including adapting existing policy and regulatory instruments to help address this issue.43
 
Remove Parallel Import RestrictionsAustralia’s parallel import restrictions is a hangover from when Australia had a domestic car industry and bans the parallel imports of second-hand vehicles.  Allan Fels found that New Zealand consumers pay an average of 41% less for second-hand electric and hybrid vehicles – $9,025 on average – because that country does not ban parallel imports of second-hand vehicles like Australia does.  Tariffs and restrictions on the import of electric vehicles are no longer sensible since the exit of car manufacturers from Australia in the preceding decade. Unless this changes, restrictions on imports create unnecessarily high prices for consumers resulting in lower uptake of EVs resulting in continued high transport emissions for Australia. The regulations in the Road Vehicle Safety Act 2018 which block parallel imports of electric vehicles should be immediately lifted.[45] [46]
 
Regulate to ban import of HFC-charged automotive air conditionersNVES impact analysis Option B and Option C do not allow for air conditioning credits together with other technology credits including super credits and off-cycle credits.  This is a good thing as it provides simplicity and transparency to the policy and does not cater to the needs of individual car makers.  Any dilution of the NVES through the inclusion of these bonus credits risks further delaying the supply of more low and zero emission vehicles to Australia.[47] These technologies are generally already included and/or will soon be required for Australian vehicles.[48]
 
However, Australian vehicles continue to be imported with air conditioners charged with the refrigerant HFC-134a.  This is a greenhouse gas with a global warming potential of 1430 times that of CO2.  Although banned from original supply in Australia, it is not banned when imported via pre- charged automotive air conditioners. The import of HFC-charged automotive air conditioners should be banned directly through regulation.[49]
 
SummaryAn NVES provides an affordable method to support the shift of Australia's vehicle fleet toward low- and zero-emission vehicles. It aims to enhance energy efficiency, reduce fuel consumption, lower operational expenses, and decrease the reliance on fossil fuels.[50]
 
The Clean Energy Association of Newcastle and Surrounds (CLEANaS) strongly supports the implementation of an aggressive Australian New Vehicle Emission Standard (NVES Option C:Fast start) that catches up with US and European emission targets, makes the Australian vehicle market highly appealing for low- and zero-emissions vehicles, maximises savings to the consumer, maximises the reduction in greenhouse gas emissions and delivers steep reductions in emissions early.[51]
 
Similar to Australia, transport emissions in the Hunter region represent over 21% of our region’s emissions and around 6% of Australia’s overall transport emissions.  In 2021/2022, 99% of these emissions were from road transport.[52] Road transport is currently filled with highly-polluting cars that are driving up transport emissions and contributing to poor air quality and deleterious health outcomes.[53]
 
Consequently, the implementation of a strong NVES has the opportunity to provide significant benefits to the local community through reduced emissions, reduced dependence on fossil fuels, and significant health and financial benefits in the near future.
 
CLEANaS is dedicated to driving the uptake of clean energy in our region, reducing our dependence on fossil fuels to a more competitive and sustainable local economy.  Clean energy initiatives must be a win-win for our local community and business, and of course the environment.  An effective and strong NVES aligns with the vision and goals of CLEANaS.
 
The continued rise in transport emissions poses a significant challenge to Australia's commitments under the Paris Agreement and its legislated 2030 emissions reduction targets. The NVES, whether through Option B or Option C, is insufficient to tackle this emission surge. Additional policies and measures are necessary.  These should include:

• Removal of Parallel Import Restrictions
• Regulate to ban the import of HFC-charged automotive air conditioners
• Policies and measures to curb increased use of cars and kms travelled
• Policies and measures to curb increased sale of larger cars

 
Option B and Option C are comparable in most respects. However, Option C offers over 19% additional benefits to consumers and over 30% more emission abatement compared to Option B by 2030. Given that transport emissions are moving in the wrong direction and offsetting gains in other sectors, it is crucial to maximise emissions reduction efforts through transport policies like the NVES. This approach is essential for Australia to fulfil its commitments under the Paris Agreement and meet its legislated 2030 emissions reduction targets. Therefore, Option C is the appropriate choice.
 
Thank you for considering our submission,

Sincerely,
 
Alec Roberts
CLEANaS Chair on behalf of CLEANaS
 


[1] http://www.cleanas.org.au/

[2] World Population Review. (2023).  CO₂ Emissions by Country 2023. Retrieved 23 November 2023, from https://worldpopulationreview.com/country-rankings/co2-emissions-by-country

[3] Swann, T. (2019, July). High Carbon from a Land Down Under: Quantifying CO2 from Australia’s fossil fuel mining and exports. https://www.tai.org.au/sites/default/files/P667%20High%20Carbon%20from%20a%20Land%20Down%20Under%20%5BWEB%5D_0_0.pdf

[4] Ritchie, H. (2019, October 4). Where in the world do people emit the most CO2? Retrieved 18 February 2024, from https://ourworldindata.org/per-capita-co2

[5] Statistica. (2023). Per capita carbon dioxide emissions worldwide in 2022, by country. Retrieved 18 February 2024, from https://www.statista.com/statistics/270508/co2-emissions-per-capita-by-country/

[6] NASA (n.d.) Scientific Consensus: Earth's Climate is Warming. https://climate.nasa.gov/scientific-consensus/

[7] BOM (2022) State of the Climate 2022.  http://www.bom.gov.au/state-of-the-climate/2022/documents/2022-state-of-the-climate-web.pdf

[8] Readfearn, G. (2020, April 7). Great Barrier Reef's third mass bleaching in five years the most widespread yet. https://www.theguardian.com/environment/2020/apr/07/great-barrier-reefs-third-mass-bleaching-in-five-years-the-most-widespread-ever

[9] Deloitte Access Economics (2017, June 23). At what price? The economic, social and icon value of the Great Barrier Reef. https://www.barrierreef.org/the-reef/the-value

[10] Deloitte Access Economics (2020, November) A new choice: Australia’s climate for growth.  https://www2.deloitte.com/content/dam/Deloitte/au/Documents/Economics/deloitte-au-dae-new-choice-climate-growth-051120.pdf?nc=1

[11] Cox, L. (2020, Oct 12). Net zero emissions target for Australia could launch $63bn investment boom.  https://www.theguardian.com/australia-news/2020/oct/12/net-zero-emissions-target-for-australia-could-launch-63bn-investment-boom

[12] Department of Climate Change, Energy, the Environment and Water (DCCEEW). (2023). Net Zero, Australian Government Department of Climate Change, Energy, the Environment and Water. https://www.dcceew.gov.au/climate-change/emissions-reduction/net-zero

[13] IPCC (2018). Global Warming of 1.5°C: An IPCC Special Report on the impacts of global warming of 1.5°C above pre-industrial levels and related global greenhouse gas emission pathways, in the context of strengthening the global response to the threat of climate change, sustainable development, and efforts to eradicate poverty, Intergovernmental Panel on Climate Change.  https://www.ipcc.ch/sr15/

[14] Australian Government. (2022). Australia’s Nationally Determined Contribution: Communication 2022. UNFCCC Nationally Determined Contributions Registry. Retrieved 24 March 2023, from https://unfccc.int/sites/default/files/NDC/2022-06/Australias%20NDC%20June%202022%20Update%20%283%29.pdf

[15] Department of Climate Change, Energy, the Environment and Water (DCCEEW). (2023). Quarterly Update of Australia’s National Greenhouse Gas Inventory: June 2023, Australian Government Department of Climate Change, Energy, the Environment and Water. Retrieved 18 February 2024 from https://www.dcceew.gov.au/climate-change/publications/national-greenhouse-gas-inventory-quarterly-update-june-2023

[16] Bureau of Infrastructure and Transport Research Economics (BITRE), 2023, Yearbook 2023: Australian Infrastructure and Transport Statistics, Statistical Report, BITRE, Canberra ACT. Retrieved 18 February 2024, from https://www.bitre.gov.au/publications/2023/australian-infrastructure-and-transport-statistics-yearbook-2023

[17] Climate Council. (2022a). Everything you need to know about how Australia can boost Electric Vehicle supply. Retrieved 25 March 2023, from https://www.climatecouncil.org.au/how-Australia-can-boost-electric-vehicle-supply/

[18] National Transport Commission. (2021). Carbon Dioxide Emissions Intensity for New Australian Light Vehicles 2021. Retrieved 03 April 2023, from https://www.ntc.gov.au/sites/default/files/assets/files/Carbon%20Dioxide%20Emissions%20Intensity%20for%20New%20Australian%20Light%20Vehicles%202021.pdf

[19] Department of Infrastructure, Transport, Regional Development, Communications and the Arts. (2024, February). Cleaner, Cheaper to Run Cars: The Australian New Vehicle Efficiency Standard: Consultation Impact Analysis. https://www.infrastructure.gov.au/department/media/publications/cleaner-cheaper-run-cars-australian-new-vehicle-efficiency-standard-consultation-impact-analysis
 

[20] Quicke, A. (2022, Aug). Fuelling efficiency. The Australian Institute. https://australiainstitute.org.au/wp-content/uploads/2022/08/P1269-Fuel-Efficiency-Standards-WEB.pdf

[21] Basford Canales, S. (2024, Feb 21). More efficient cars could almost halve Australians’ yearly petrol costs, new analysis shows. https://www.theguardian.com/australia-news/2024/feb/21/more-efficient-cars-could-almost-halve-australians-yearly-petrol-costs-new-analysis-shows

[22] IEA. (2022). Global EV Outlook. Retrieved 18 February 2024, from https://www.iea.org/reports/global-ev-outlook-2022

[23] Mandala. (2023, June).  Raising standards, cutting costs: How an effective new vehicle efficiency standard can reduce vehicle emissions and save consumers money. https://electricvehiclecouncil.com.au/wp-content/uploads/2023/07/Raising-standards-cutting-costs.pdf

[24] Naidoo, V. (2023, Nov 12). What would fuel efficiency standards mean for Australia? https://www.drive.com.au/caradvice/australia-fuel-efficiency-standards-explained/

[25] Cooke, D. (2019, Sep 5).  Today’s Vehicles, Tomorrow: How Automakers Can Meet Strong 2025 Efficiency Standards. https://blog.ucsusa.org/dave-cooke/automakers-2025-efficiency-standards/

[26] Calma, J. (2023, Dec 22). American automakers are losing the race to make more fuel-efficient vehicles. https://www.theverge.com/2023/12/21/24010938/car-suv-truck-fuel-efficiency-emissions-epa-trends-report

[27] European Commission. (n.d.). CO₂ emission performance standards for cars and vans. https://climate.ec.europa.eu/eu-action/transport/road-transport-reducing-co2-emissions-vehicles/co2-emission-performance-standards-cars-and-vans_en

[28] Engineers Australia. (2023, May 31). Fuel Efficiency Standard submission. https://www.engineersaustralia.org.au/publications/fuel-efficiency-standard-submission

[29] Vehicle Certification Agency. (2022). New UK Car and Van CO2 Regulations: Guidance for manufacturers on the legislation governing CO2 emissions from new cars and vans sold in the UK. https://www.vehicle-certification-agency.gov.uk/download-publication/3899/New-Car-and-Van-CO2-Regulations-Guidance-2022/#:~:text=3.2%20The%20latest%20Regulation%2C%20(EU,for%20cars%20and%20vans%20respectively

[30] Somerville, P. & Hollingworth, K. (2022). Electric vehicles help farmers drive savings and lower carbon footprint. https://www.abc.net.au/news/rural/2022-06-05/electric-vehicles-side-by-side-farm-inputs-environment/101121922

[31] Credintino, J. (2023). Australian farmers show electric cars can work in the middle of nowhere.  https://www.carexpert.com.au/car-news/australian-farmers-show-electric-cars-can-work-in-the-middle-of-nowhere

[32] Farmers for Climate Action. (2023, February 23). Electric Vehicles on Farms - 23 Feb 2023. [Video]. Youtube. https://www.youtube.com/watch?v=jrWCO_fhL7s

[33] Quattromani, G. (2022, Oct 27). I Made The Switch To An Electric, Battery Powered Dirt Bike: Here’s How It Went. https://menshealth.com.au/surron-storm-bee-f-electric-motor-bike-review/

[34] Carter, L. Quicke, A. & Armistead, A. (2022, April). Over a barrel - Addressing Australia’s Liquid Fuel Security. The Australia Institute. https://australiainstitute.org.au/report/over-a-barrel/

[35] Department of Foreign Affairs and Trade. (2023). Australia’s trade in goods and services 2021-22. https://www.dfat.gov.au/trade/trade-and-investment-data-information-and-publications/trade-statistics/trade-in-goods-and-services/australias-trade-goods-and-services-2021-22

[36] Joshi, K. (2024, Feb 17). Big cars are dead weight dragging down climate policy. https://ketanjoshi.co/2024/02/17/car-companies-are-wrecking-climate-efforts-to-make-money/

[37] Climate Change Authority. (2023, Jun 29). Opportunities to reduce light vehicle emissions in Australia. https://www.climatechangeauthority.gov.au/reviews/light-vehicle-emissions-standards-australia/opportunities-reduce-light-vehicle-emissions

[38] Musso, A., & Dalla Chiara, B. (2017). Case studies on transport policy. Case Studies on Transport Policy, 5(2), 389–391. https://doi.org/10.1016/j.cstp.2017.04.001

[39] Kuss, P., & Nicholas, K. A. (2022). A dozen effective interventions to reduce car use in European cities: Lessons learned from a meta-analysis and transition management. Case Studies on Transport Policy, 10(3), 1494–1513. https://doi.org/10.1016/j.cstp.2022.02.001

[40] Doctors for the Environment Australia. (2024, February 7). Doctors: New Vehicle Efficiency Standard will save lives on our roads. https://dea.org.au/doctors-new-vehicle-efficiency-standard-will-save-lives-on-our-roads/

[41] Thrower, J. (2024, Jan 12). SUVs and utes are no longer just work vehicles, but tax-subsidised behemoths.  https://australiainstitute.org.au/post/suvs-and-utes-are-no-longer-just-work-vehicles-but-tax-subsidised-behemoths/

[42] Cazzola, P., Paoli, L. and Teter, J. (2023, November). Trends in the global vehicle fleet 2023: Managing the SUV shift and the EV transition. Global Fuel Economy Initiative. IEA. https://www.globalfueleconomy.org/data-and-research/publications/trends-in-the-global-vehicle-fleet-2023

[43] IEA (2021), Global Fuel Economy Initiative 2021, IEA, Paris https://www.iea.org/reports/global-fuel-economy-initiative-2021 , Licence: CC BY 4.0

[44] Climate Council. (2023, May 30). Submission to: Fuel efficiency standard consultation. https://www.climatecouncil.org.au/resources/submission-to-fuel-efficiency-standard-consultation/

[45] Fells, A. (2024, Feb). Inquiry into price gouging and unfair pricing practices. Final Report. https://pricegouginginquiry.actu.org.au/wp-content/uploads/2024/02/InquiryIntoPriceGouging_Report_web.pdf

[46] Braue, D. (2024, Feb 15). EVs in Australia cost $9,025 more than they should - But regulatory changes are about to fix that. https://ia.acs.org.au/article/2024/evs-in-australia-cost--9-025-more-than-they-should.html

[47] Bleakley, D. (2023). EV Council says vehicle standard needs to catch up with rest of world before 2030. The Driven.  https://thedriven.io/2023/05/25/ev-council-says-vehicle-standards-needs-to-catch-up-with-rest-of-world-before-2030/

[48] Whitehead, J. (2023). Recommendations for an Australian New Vehicle Efficiency Standard. Electric Vehicle Council. https://electricvehiclecouncil.com.au/reports/recommendations-for-anaustralian-new-vehicleefficiency-standard/

[49] Pocock, D. (2023, May 31). Response to: The Fuel Efficiency Standard – Cleaner, Cheaper to run Cars for Australia. https://www.davidpocock.com.au/strong_fuel_efficiency_standards

[50] Smit, R., Khan, T. & Yang, Z. (2024, Feb). How Australian light-duty vehicle CO2 emissions compare with the rest of the world. ICCT. https://theicct.org/publication/australian-ldv-co2-emissions-compare-to-the-rest-of-the-world-feb24/

[51] Climate Council. (2021, Aug 30). Emission Reduction Targets: What you need to know. https://www.climatecouncil.org.au/wp-content/uploads/2021/10/Explainer-Emissions-Reduction-Targets-October-2021.pdf

[52] Ironbark Sustainability and Beyond Zero Emissions. (2023). 2022 Snapshot emissions profile – Ironbark Sustainability and Beyond Zero Emissions. Snapshot. Retrieved 24 February 2024, from https://snapshotclimate.com.au/

[53] Bicycle Network (2024, Feb 15). Share your thoughts on Australia's new fuel efficiency standards. https://bicyclenetwork.com.au/newsroom/2024/02/15/share-your-thoughts-on-australias-new-fuel-efficiency-standards/
 

Download a pdf copy of the submission here or read the submission online below.

23/11/2020
 
Committee Secretary
Senate Standing Committees on Environment and Communications
Parliament House
PO Box 6100
Canberra ACT 2600
[email protected]
 
Climate Change Amendment (Duty of Care and Intergenerational Climate Equity) Bill 2023
 
To the Senate Standing Committees on Environment and Communications regarding the Climate Change Amendment (Duty of Care and Intergenerational Climate Equity) Bill 2023
 
Dear Committee Secretariat,
 
Thank you for the opportunity to provide a submission into the Climate Change Amendment (Duty of Care and Intergenerational Climate Equity) Bill 2023 and taking the time to consider our submission.
 
This is a submission supporting the Climate Change Amendment (Duty of Care and Intergenerational Climate Equity) Bill 2023.
 
The government is responsible for the environment, the health and wellbeing of its citizens, and the financial security of the nation. As we see the impact of increased carbon emissions, we also find evidence of the deleterious impact on Australian native wildlife, the Australian people and the wealth of the nation.  There is only 4 years left at present emission rates of the 2013-2050 emission budget to stay below 1.5°C. Therefore, at current emissions rates, Australia will have exceeded its carbon budget for 2050 by 2027. By 2055 Australia will experience economic losses on par with covid, getting worse every single year due to unchecked climate change.5
 
However, those that will suffer the most from the effects of climate change, children and future generations, are the least protected, with current Australian climate change legislation lacking on the rights of children and future generations.
 
The IPCC stated that global emissions need to reach net zero by 2050 to be consistent to limiting warming to 1.5 °C.5 Furthermore, The IEA (2021) stated that to achieve net zero by 2050, no new oil and gas fields should be approved for development together with no new coal mines or mine extensions.[1]
 
CLEANaS is the Clean Energy Association of Newcastle and Surrounds, a not-for-profit association formed in 2012 by a group of locals passionate about clean energy.[2] CLEANaS is dedicated to driving the uptake of clean energy so that our region can transition from its current dependency on fossil fuels to a more competitive and sustainable local economy. We achieve this by working with our partners to demonstrate profitable community-led and community-owned clean energy projects; raise the profile of clean energy in the local economy through education and awareness raising; and by improving access to financing mechanisms and affordable technologies so that investment and activity grow. Our initiatives must deliver a win-win for local community investors, local enterprise and, of course, our environment.
 
Climate Change ImpactsThe impacts of climate change on the environment are significant and severe. The present scientific consensus is that the earth's climate is warming due to human activity, and the negative impacts of increased greenhouse gas emissions are measurable globally and nationally.[3]
 
Australia’s climate has warmed on average by 1.47 ± 0.24 °C since national records began in 1910, which has led to an increase in the frequency of extreme heat events.[4] The Bureau of Meteorology and CSIRO reported that there has been an increase in extreme fire weather, and in the length of the fire season, across large parts of the country since the 1950s, as evidenced by the catastrophic bushfires in the summer of 2019/2020.  They also noted changes in rainfall, with decreases in the southeast and southwest of Australia as shown by the devastating drought in 2019.  Oceans around Australia they stated are acidifying and have warmed by about 1°C since 1910 bringing longer and more frequent marine heatwaves.  In the past 5 years there have been three major mass-bleaching events at the Great Barrier Reef resulting from these marine heatwaves, and resulting in the destruction of over half of the reef’s corals.[5]  The Great Barrier Reef has an economic, social and iconic asset value estimated at $56 billion, contributes around $6.4 billion annually to the Australian economy and supports over 64,000 jobs.[6]  Sea levels are also rising around Australia, increasing the risk of coastal inundation and damage to infrastructure and communities.2
 
The government is responsible for the environment, the health and wellbeing of its citizens, and the financial security of the nation. As we see the impact of increased carbon emissions, we also find evidence of the deleterious impact on Australian native wildlife, the Australian people and the wealth of the nation. 
 
Emission goals and carbon budgetsTo address the issue of dangerous climate change, Australia, along with 196 other parties, is a signatory to the Paris Agreement, which entered into force on 4 November 2016. The Paris Agreement aims to strengthen the global response to the threat of climate change, by:
Holding the increase in the global average temperature to well below 2°C above pre-industrial levels and pursuing efforts to limit the temperature increase to 1.5°C above pre-industrial levels, recognising that this would significantly reduce the risks and impacts of climate change.[7]
In 2020 Australia emitted 1.1% of world greenhouse gas emissions. This made Australia the world’s 16th biggest emitter of greenhouse gas pollution, despite having just 0.33% of world population.[8]  On a per capita basis. Australian emissions are the highest in the OECD and among the highest in the world. The only countries with higher per capita emissions than Australia are smaller petro-states like Kuwait, Qatar and UAE and some Small Island Developing States. [9] [10] [11]
 
 
Australia has a target to achieve net zero emissions by 2050. Furthermore, in 2022, The Australian Government increased the ambition of its 2030 target in 2022, committing to reduce greenhouse gas emissions 43% below 2005 levels by 2030[12] .
 
It should be noted that Australia’s commitment is insufficient to limit warming to 1.5C.  The IPCC calculated level of GHG reductions required by 2030 to limit warming to 1.5C is a 43% GHG reduction based on 2019 emissions.  Adjusting this figure for Australia’s baseline year of 2005 (a particularly high emission year) results in a required 48% reduction in emissions (below 2005 levels) required by 2030 to ensure a >50% chance of limiting warming to 1.5°C[13] [14]. The Climate Council and Climate Targets Panel both recommend that Australia cut its emissions 74-75% (based on 2005 levels) by 2030, and aim to reach net zero by 2035 to remain within 1.5C warming[15] [16] .
 
The IPCC report provides an estimate for a global remaining carbon budget of 580 GtCO2 (excluding permafrost feedbacks) based on a 50% probability of limiting warming to 1.5 degrees relative to 1850 to 1900 during and beyond this century and a remaining carbon budget of 420 GtCO2 for a 67% chance.[17]
 
Committed emissions from existing and proposed energy infrastructure represent more than the entire carbon budget that remains if mean warming is to be limited to 1.5 °C and perhaps two-thirds of the remaining carbon budget if mean warming is to be limited to less than 2 °C.  Estimates suggest that little or no new CO2-emitting infrastructure can be commissioned, and that existing infrastructure may need to be retired early in order to meet the Paris Agreement climate goals.[18]
 
From Jan 2017 until 2050 Australia’s remaining emission budget for a 50% chance of warming to stay below 1.5C warming relative to pre-industrial levels was estimated to be 5.5 GTCO2e.7  Adding the GHG emissions expended from 2017 until 2022[19] [20], this leaves just 2.5 Gt CO2e remaining as at December 2022 which equates to only 4 years left at present emission rates of the 2013-2050 emission budget to stay below 1.5°C.  Therefore, at current emissions rates, Australia will have exceeded its carbon budget for 2050 by 2027.
 
Economic risksDeloitte Access Economics noted that some of the most significant risks to Australia’s economic growth trajectory are from the physical risks associated with a changing climate and the unplanned economic transition risk from the world’s response to this changing climate.16
Their analysis showed that the Australian industries hardest hit by the Covid 19 pandemic would also be the most vulnerable to the effects of a warming world and climate change. Australia’s agriculture, construction, manufacturing, tourism related industries and mining sectors all featured consistently in the top industries exposed to the risks of covid, climate change and the unplanned economic transition as the world responds.  Deloitte Access Economics estimated that by 2055 Australia will experience economic losses on par with Covid 19.16
 
Net Zero Emissions by 2050The IPCC stated that global emissions need to reach net zero by 2050 to be consistent to limiting warming to 1.5 °C.5  Modelling has shown that moving towards a net zero emissions economy would unlock financial prospects in sectors including manufacturing and renewables triggering a $63 billion investment boom.[21]  Deloitte Access Economics estimates such a new growth recovery could grow Australia’s economy by $680 billion (present value terms) and increase GDP by 2.6% in 2070 – adding over 250,000 jobs to the Australian economy by 2070.[22] 
 
The Australian Government has now committed to developing a 2050 Net Zero plan and 2035 emission reduction targets consistent with Australia’s international and domestic commitments.[23]  However, since May 2022, 4 new coal mines or expansions were approved in Australia that will result in an additional 147 million tonnes of carbon emissions. An additional 25 additional proposals for new or expanded coal mines are currently awaiting Federal Government approval that would release over 12 billion tonnes of carbon emissions if approved.[24]  The International Energy Agency (2021) stated that to achieve net zero by 2050, no new oil and gas fields can be approved for development together with no new coal mines or mine extensions.[25]
 
Intergenerational EquityFailing to act on climate change today will result in the costs and damages of climate change increasing over time, with these burdens being borne by future generations.[26] [27] The Principle of Equality states that all generations should bear a similar weight for the burdens of climate change, and that all generations are obligated to not violate intergenerational or intragenerational equality.[28] So future generations should not bear substantially greater burdens or responsibilities for climate change compared to previous generations, and that individuals and groups within generations ought to bear comparable burdens and responsibilities to each other.
 
Weiss (2008)[29] in their seminal article on the theory of intergenerational equity stated that global climate change induced by human activities “raises serious issues of justice between the present generation and future generations, and between communities within future generations”. Weiss claimed that as all generations interact with the earth, every generation needs to pass the Earth and its resources on in at least as good a condition or a better condition than it was received. Weiss proposed 3 principles of intergenerational equity, specifically that present generations conserve the diversity of natural resources for future generations, ensuring the quality of the environment is comparable between generations and generations have similar access to the earth and its resources.  However, the environment is deteriorating at an increasing rate due in part to climate change, such as increasing temperatures, rising sea levels, and species extinctions.  Furthermore, natural resources likely impacted by climate change include land for habitation or agriculture, and fresh water sources. Nguyen (2021) noted that if we do not act to address climate change, resources over time will dwindle which will threaten the prospects of future generations having equitable access to resources as compared to present or past generations.
 
Weiss (2008) concluded that to fulfil our responsibility to future generations we must respect the principles of intergenerational equity and strategies to combat climate change need to reflect the principles of intergenerational equity.
 
Children and Climate ChangeAustralia is a signatory to the Convention on the Rights of the Child (CRC) which recognises that children have the same human rights as adults, while also needing special protection due to their vulnerability.  The guiding principles of the CRC includes putting the best interests of the child first in all decisions that affect them.  The Committee on the Rights of Children, that monitors implementation of the CRC, recently emphasised the urgent need to address the adverse effects of climate change on children’s rights and that “Governments should consider children’s rights in all decisions made about climate change and consider climate change in all decisions being made about children”[30] .
 
Children are especially vulnerable and will suffer disproportionately to the effects of climate change.  They have little say in climate policy decisions that will contribute to future climate impacts and have little or no control over the environment that they will inherit.  Children are already experiencing the impacts of climate change through climate change fueled climate and environmental hazards, impacting on their current and future wellbeing. UNICEF stated that approximately 1 billion children are at an “extremely high risk” of the impacts of climate change.[31]
 
Those that have contributed the least to climate change, children, those in poverty, and future generations are the most affected. Save the Children stated that due to climate change:

• The education of around 38 million children is disrupted each year,
• Almost 160 million children are exposed to increasingly severe and prolonged droughts,
• 90% of diseases resulting from climate change are likely to affect children under the age of five,
• By 2040, it is estimated that one in four children will be living in areas with extreme water shortages, and
• By 2050, a further 24 million children are projected to be undernourished,[32]

 
This BillCLEANaS supports the passing of this Duty of Care and Intergenerational Climate Equity bill. 
 
Currently, Australian legislation is ill-equipped to address the human rights impacts of climate change for both children and future generations.  This bill establishes a clear obligation for Government Ministers and decision-makers to consider the potential impacts of climate change on future generation’s wellbeing.
 
In particular the bill would create a new duty of care of decision makers to consider the health and wellbeing of current and future generations when considering decisions that may worsen the effects of climate change such as commissioning new fossil fuel infrastructure (such as the Gas fired power station currently being built in Kurri Kurri here in the Hunter Valley that will be incapable of running on more than 30% hydrogen even with additional investment[33]) or the approval of new fossil fuel mines or mine extensions (such as the Mount Pleasant Coal Mine in the Hunter Valley that will result in 876 million tonnes of emissions).
 
Furthermore, the bill would prohibit decisions that would lead to levels of emissions that pose a risk to the health and wellbeing of children and would promote intergenerational equity within government decision making. 
 
As additional emissions result in greater impacts of climate change no matter where they are created (in Australia or Overseas), the impact of this proposed legislation on a decision to approve a fossil fuel project would not depend on location of the infrastructure or where the emissions are created. This would also include decisions on public funding and loans for fossil fuel infrastructure projects.  The decision maker would also need to take into consideration if the emissions resulting from such a decision would impact on Australia’s emission reduction targets.
 
 
CLEANaS strongly supports imposing a duty of care on decision-makers to consider the health and well-being of current and future children in Australia when making administrative decisions that contribute to climate change and urges the Commonwealth Government to support the Duty of Care and Intergenerational Climate Equity bill.
 
Thank you for considering our submission,

Sincerely,
 
 
Alec Roberts
CLEANaS Chair on behalf of CLEANaS
 
 
 


[1] IEA. (2021). Net Zero by 2050. A Roadmap for the Global Energy Sector. Retrieved from https://www.iea.org/reports/net-zero-by-2050

[2] http://www.cleanas.org.au/

[3] NASA (n.d.) Scientific Consensus: Earth's Climate is Warming.  Retrieved from https://climate.nasa.gov/scientific-consensus/

[4] BOM (2022) State of the Climate 2022.  Retrieved from http://www.bom.gov.au/state-of-the-climate/2022/documents/2022-state-of-the-climate-web.pdf

[5] Readfearn, G. (2020, April 7). Great Barrier Reef's third mass bleaching in five years the most widespread yet. Retrieved from https://www.theguardian.com/environment/2020/apr/07/great-barrier-reefs-third-mass-bleaching-in-five-years-the-most-widespread-ever

[6] Deloitte Access Economics (2017, June 23). At what price? The economic, social and icon value of the Great Barrier Reef. Retrieved from https://www.barrierreef.org/the-reef/the-value

[7] IPCC (2018). Global Warming of 1.5°C: An IPCC Special Report on the impacts of global warming of 1.5°C above pre-industrial levels and related global greenhouse gas emission pathways, in the context of strengthening the global response to the threat of climate change, sustainable development, and efforts to eradicate poverty, Intergovernmental Panel on Climate Change.  Retrieved from https://www.ipcc.ch/sr15/

[8] World Population Review. (2023).  CO₂ Emissions by Country 2023. Retrieved 23 November 2023, from https://worldpopulationreview.com/country-rankings/co2-emissions-by-country

[9] Swann, T. (2019, July). High Carbon from a Land Down Under:  Quantifying CO2 from Australia’s fossil fuel mining and exports. Retrieved from https://www.tai.org.au/sites/default/files/P667%20High%20Carbon%20from%20a%20Land%20Down%20Under%20%5BWEB%5D_0_0.pdf

[10] Ritchie, H. (2019, October 4). Where in the world do people emit the most CO2? Retrieved from https://ourworldindata.org/per-capita-co2

[11] Statistica. (2023). Per capita carbon dioxide emissions worldwide in 2021, by country. Retrieved 23 November 2023, from https://www.statista.com/statistics/270508/co2-emissions-per-capita-by-country/

[12] Australian Government. (2022). Australia’s Nationally Determined Contribution: Communication 2022. UNFCCC Nationally Determined Contributions Registry. Retrieved 24 March 2023, from https://unfccc.int/sites/default/files/NDC/2022-06/Australias%20NDC%20June%202022%20Update%20%283%29.pdf

[13] Intergovernmental Panel on Climate Change (IPCC). (2023). Climate Change 2023: Synthesis Report. Contribution of Working Groups I, II and III to the Sixth Assessment Report of
the Intergovernmental Panel on Climate Change. Retrieved from https://www.ipcc.ch/report/ar6/syr/

[14] Australian Bureau of Statistics (ABS). (2008). 4613.0 - Australia's Environment: Issues and Trends 2007. Australian Bureau of Statistics. Retrieved 25 March 2023, from https://www.abs.gov.au/ausstats/[email protected]/2f762f95845417aeca25706c00834efa/4FC4AA7DF35CC331CA2573C60010400D?opendocument#:~:text=Australia's%20net%20greenhouse%20gas%20emissions,were%20102.2%25%20of%201990%20levels.

[15] Climate Council (2022) Labor’s 2030 emissions targets must aim higher and go faster. Retrieved 4 June 2023, from https://www.climatecouncil.org.au/resources/labors-2030-emissions-targets-must-aim-higher/

[16] Climate Targets Panel (2021) Australia’s Paris Agreement Pathways: Updating the Climate Change Authority’s 2014 Emissions Reduction Targets. Retrieved 4 June 2023, from https://www.climatecollege.unimelb.edu.au/files/site1/docs/%5Bmi7%3Ami7uid%5D/ClimateTargetsPanelReport.pdf

[17] Meinshausen, M. (2019, March 19). Deriving a global 2013-2050 emission budget to stay below 1.5°C based on the IPCC Special Report on 1.5°C.  Retrieved from https://www.climatechange.vic.gov.au/__data/assets/pdf_file/0018/421704/Deriving-a-1.5C-emissions-budget-for-Victoria.pdf

[18] Tong, D., Zhang, Q., Zheng, Y., Caldeira, K., Shearer, C., Hong, C., Qin, Y., & Davis, S. J. (2019). Committed emissions from existing energy infrastructure jeopardize 1.5 °C climate target. Nature, 572(7769), 373-377. https://doi-org.ezproxy.newcastle.edu.au/10.1038/s41586-019-1364-3

[19]  Department of Climate Change, Energy, the Environment and Water (DCCEEW). (n.d.). Australia's National Greenhouse Accounts: Paris Agreement inventory. Retrieved 19 Nov 2023 from   https://greenhouseaccounts.climatechange.gov.au/

[20] 2022 Snapshot emissions profile – Ironbark Sustainability and Beyond Zero Emissions.

[21] Cox, L. (2020, Oct 12). Net zero emissions target for Australia could launch $63bn investment boom.  Retrieved from https://www.theguardian.com/australia-news/2020/oct/12/net-zero-emissions-target-for-australia-could-launch-63bn-investment-boom

[22] Deloitte Access Economics (2020, November) A new choice: Australia’s climate for growth.  Retrieved from https://www2.deloitte.com/content/dam/Deloitte/au/Documents/Economics/deloitte-au-dae-new-choice-climate-growth-051120.pdf?nc=1

[23] Department of Climate Change, Energy, the Environment and Water (DCCEEW). (2023). Net Zero, Australian Government Department of Climate Change, Energy, the
Environment and Water. Retrieved 23
November 2023, from https://www.dcceew.gov.au/climate-change/emissions-reduction/net-zero

[24] The Australia Institute. (n.d). Project Coal Mine Tracker. Retrieved 23 November 2023 from https://australiainstitute.org.au/initiative/coal-mine-tracker/

[25] IEA. (2021). Net Zero by 2050. A Roadmap for the Global Energy Sector. Retrieved from https://www.iea.org/reports/net-zero-by-2050

[26] Gardiner, S. (2001) The Ethical Tragedy of Climate Change: A Perfect Moral Storm. Oxford University Press, p. 143.

[27] Nguyen, J.M. (2021). Cosmopolitan Intergenerational Justice and Climate Change. [PhD thesis, University of California, Irvine]. eScholarship. https://escholarship.org/content/qt2h50d7p0/qt2h50d7p0.pdf?t=r052rd

[28] Schuppert, F. (2011) Climate Change Mitigation and Intergenerational Justice. Environmental Politics. Vol 20, No.3.. p. 307.

[29] Weiss, E.B. (2008). Climate Change, Intergenerational Equity and International Law. Vermont Journal of Environmental Law. Retrieved from https://scholarship.law.georgetown.edu/cgi/viewcontent.cgi?article=2637&context=facpub

[30] Committee on the Rights of the Child (2023). CRC/C/GC/26: General comment No. 26 (2023) on children’s rights and the environment with a special focus on climate change.  Retrieved 123 November 2023 from https://www.ohchr.org/en/events/events/2023/launch-general-comment-no-26-2023-childrens-rights-and-environment-special-focus

[31] UNICEF. (2021). The impacts of climate change put almost every child at risk.  Retrieved from https://www.unicef.org/stories/impacts-climate-change-put-almost-every-child-risk

[32] Save the Children. (n.d.).  The Climate Crisis: Climate Change Is a Grave Threat to Children’s Survival. Retrieved from https://www.savethechildren.org/us/what-we-do/emergency-response/climate-change

[33] Snowy Hydro. (n.d.) Hunter Power Project. Retrieved from https://www.snowyhydro.com.au/hunter-power-project/

Climate Change and Resource Efficiency Policy Branch
NSW Office of Environment and Heritage
 
Thank you for the opportunity to provide input to the Climate Change Fund Draft Strategic Plan 2017 to 2022.
 
CLEANaS is the Clean Energy Association of Newcastle and Surrounds, a not-for-profit association formed in 2012 by a group of locals passionate about clean energy. CLEANaS is dedicated to driving the uptake of clean energy that our region can transition from our current dependency on fossil fuels to a more competitive and sustainable local economy. We will achieve this by working with our partners to demonstrate profitable community-led and community-owned clean energy projects; raise the profile of clean energy in the local economy through education and awareness raising; and by improving access to financing mechanisms and affordable technologies so that investment and activity grow. Our initiatives must deliver a win-win for local community investors, local enterprise and, of course, our environment.
 
Accelerating advanced energy: Attract investment in advanced energy and save emissions
 
Unlock investment under the Renewable Energy Target - Maximise investment under the national Renewable Energy Target
 
 
This plan proposes to support up to 540 MW of renewable energy projects over five years. This amount must be increased five-fold. NSW is far behind other states when it comes to attracting renewable energy investment and jobs. For comparison in the ACT “… the first round 2014 Amendment Bill to the Act was passed, entitling the Minister to issue feed-in tariffs (FiTs) for up to 550MW of generation capacity…’.  http://www.environment.act.gov.au/__data/assets/pdf_file/0009/796599/ACT-Wind-Auction-Review-Summary-report-final.pdf
​
NSW with a population about 20 times larger than the ACT should act accordingly.
 
Green Bonds
Green Bonds raise funds for new and existing projects with environmentally sustainable benefits.  Green bonds can be issued to institutional investors, retail investors or a mix of the two.  The Victorian government recently issued Green Bonds through Treasury Corporation of Victoria (TCV).  The Green Bonds proceeds will go to financing and refinancing Victorian State investments in energy efficiency, renewable energy generation, low carbon public transport and water treatment.
http://www.premier.vic.gov.au/victorian-green-bonds-an-australian-and-world-first/
 
TCorp (the commercial arm of NSW State Treasury) could create and administer Green Bonds to provide financing for various state-backed infrastructure projects in energy efficiency, renewable energy generation, low carbon public transport, etc.  This would free up the Climate Change Fund for use in initiatives not eligible for commercial financing.  If the green bond was issued for retail investors (similar to Waratah Bonds) this would allow broad-based community investors to be engaged in supporting green initiatives such as renewable energy projects.
 
Energy Market Reform
 
Energy market reform should be a strong priority for the NSW government.  The NSW Government needs to advocate this with the COAG Energy Council.
 
We support the government’s initiative to sponsor energy market reforms to improve network connection processes.  For Community Energy projects not focussed on behind-the-meter this is key impediment to medium-sized projects.  This reform would hopefully include the gas network in addition to the NEM.
 
National Electricity Objective
There is currently no requirement or mechanism to ensure that emissions reduction and energy market policies operate together. Nor does the governance of the NEM draw on the expertise of the bodies responsible for advising on and implementing emissions reduction policy.
http://www.chiefscientist.gov.au/2016/12/media-release-future-security-of-the-national-electricity-market/
 
As an initial step both the National Electricity Objective and the National Gas Objective need to be amended to include an environmental or emissions reduction objective.  These objectives guide the AEMC, AEMO and the AER in executing their respective responsibilities.
 
Ancillary services market
The reliability and security of the national electricity system is a key part of the National Electricity Objective.  Ancillary services supporting this reliability and security are currently provided by thermal generators in the NEM.  As synchronous generators such as thermal coal generators are increasingly displaced by non-synchronous generators such as wind and solar, little has been done to ensure that ancillary services are maintained throughout the NEM.  For example wind and solar are not currently configured to provide ancillary services. 
 
The price of electricity in the NEM does not distinguish between sources of electricity or the contribution those sources make to the security and reliability of the system as a whole.  The creation/expansion of an ancillary service markets would help address these issues.
 
Settlement Period
In the wholesale electricity market generation is dispatched and priced every 5 minutes, but the market is only “settled” every 30 minutes.  This allows for the market to be “gamed” by generators (typically gas), who might push the price to the market cap for one five minute period, knowing that the benefits will flow.  If the price was settled every 5 minutes, then the distortions would be removed and fast-response technologies such as battery storage could be encouraged, leading to a smarter, cleaner and more secure grid.
 
Accelerate advanced energy technologies - Attract investment in advanced energy demonstration projects
Most emphasis to date on renewable energy has been on variable renewable electricity generators such as wind and solar PV.  Gas-fired generators are well-placed to complement variable renewable electricity generators as dispatchable generation.  However, Australia’s east coast gas market has undergone profound change with the expansion of our liquefied natural gas export industry. Domestic gas prices have risen considerably as Australian gas markets have become linked to international markets and supply has been tight. Furthermore, CO2 emissions from gas although being 60% of black coal, should not be considered an end solution for dispatchable generation.

http://www.environment.gov.au/system/files/resources/b24f8db4-e55a-4deb-a0b3-32cf763a5dab/files/national-greenhouse-accounts-factors-2014.pdf

Renewable technologies that provide dispatchable generation and storage technologies that enable variable renewable energy to become dispatchable need to be considered.

These include Solar Thermal power stations, Biogas and Combined Heat Power plants, and Pumped Hydro Energy Storage, and Battery Storage. 

Biogas with Biomethane upgrading plant would provide a renewable alternative to natural gas.  In Australia to date there has not been any upgrading of biogas to biomethane to allow it to be used in the gas grid or used as a transport fuel.
 
Make New South Wales the centre for advanced energy innovation - Provide start-up funding to accelerate innovation in advanced energy
Set up regional hubs for green-tech startups.
 
Accelerate the transition to a 21st century transport fleet - Put the New South Wales vehicle fleet on the path to doubling energy productivity
 
Other potential actions could include:
Investigate renewable gas (biomethane) as low emission vehicles for long haul vehicles to replace diesel.
Invest in public electric vehicle charging infrastructure between towns and cities to decrease range anxiety (which is one of the main deterrents to the adoption of electric vehicles).

Work with local councils to deploy public electric vehicle charging infrastructure within towns and cities.
Provide incentives to EV use - such as use of transit lanes in cities during peak periods.

Better urban planning together with bike lanes and safe and direct foot paths will reduce the amount of car travel and reduce carbon emissions.
 
Empower local communities to adopt renewable energy - Build capacity of local communities to deliver and own renewable energy
CLEANaS would like to congratulate the NSW Government on: the leadership it has shown in supporting community energy over the last few years, and for continuing to recognise the importance of community energy in the Draft Strategy Plan and broader transition to a clean energy future in NSW.  CLEANaS is supportive of the initiative to ‘sponsor energy market and financial regulation reforms through COAG to make it easier for community scale projects to connect to the grid and share their benefits.’ 

CLEANaS believes that debt or equity crowdfunding, should it become available in Australia, will remove a key barrier to the growth of broad-based community owned local renewable energy schemes. Crowd Sourced Equity Funding schemes available in other countries, such as those facilitated by Mosaic Solar in the US (www.joinmosaic.com), have demonstrated the potential for small investors to drive development of local renewable energy projects. See also our input on this under section ‘Energy Market Reform’ above.

The Regional Clean Energy Program has been an important first step in establishing a community energy sector in NSW.  This needs to be extended and further developed into a set of policy mechanisms to support community energy development within NSW.  These would include:
1. The adoption of the Smart Energy Communities policy.  This includes:

• The establishment of at least 10 community hubs like Victoria’s Moreland Energy Foundation across NSW, to provide expertise, advice, coordination and support for community energy initiatives in their region.
• Provision of grant funding for community energy projects
• Funding for a network to provide capacity building support and information sharing across the state.

 
This policy could be implemented unilaterally by NSW or as part of a national partnership with other jurisdictions similar to the National Landcare Program.
https://d3n8a8pro7vhmx.cloudfront.net/solarcitizens/pages/1211/attachments/original/1461219971/Community_Powerhouses_Policy_-_Homegrown_Power_Plan.pdf?1461219971
 
 
2. The establishment of a community energy target.  We suggest that a target of 5-10% of NSW’s renewable supply by 2025 should aim to be delivered from community energy projects.
 
3. That a policy mechanism be developed to help meet this target.  Big gains can be made by creating a fit-for- purpose financial policy mechanism for community energy projects in order to leverage community, public and private finance.  
 
4. Proactive encouragement of partial community ownership or sophisticated benefit sharing schemes for the large-scale renewable energy projects delivering through the Contracts for Difference process proposed in Section 2.1 of the Draft Strategic Plan. 
 
Community support to clean energy and environmental issues within our region is strong and there are many examples where community has come together  to support these activities through donations of time and money. Local people want to see the expansion of renewable energy and reduced reliance on conventional energy services. They also want to see the local economy diversify so as to capitalise on green economic opportunities including green jobs and markets. They also want to take control of their energy costs and have access to the means of managing their energy risks.

This requires investment, and CLEANaS believes that community is ready and willing to lead the way as long as there are clear and tangible shared benefits with strong local ownership and control.

Local investors for local benefit!
Our aim is therefore to involve broad-based community investors in profitable renewable energy projects which not only deliver a return on the investment but which also provide other tangible benefits to the local community. These other benefits include, strengthening the local renewable energy industry, reducing energy costs and risks to local business and social services, providing local people with an opportunity to engage in addressing global issues.

Community energy challenges
Community energy groups and projects face a raft of challenges in part due to the energy system and policies are not set up for democratically owned, mid-scale, decentralised energy.  Furthermore rules, regulations and laws are also not set up for community enterprises.
 
Financing for community energy projects is a hard nut to crack within Australia. 
For example, the 20/12 investor rule within the Corporations Act limits most projects to 20 ‘astute’ investors.  This in general precludes the involvement of broad-based community investors.
https://onestepoffthegrid.com.au/how-equity-crowd-funding-could-transform-the-community-energy-sector/
 
To seek investment from more than 20 investors, a community energy project most likely will need to be covered by an Australian Financial Services Licence, have a Prospectus, and undertake significant annual reporting. All of these add to the upfront and ongoing costs of a community solar project. For <100kW projects, the income generated from the sale of electricity is unlikely to cover these additional costs.  Systems of over 400kW are generally needed to cover these costs.
 
http://www.embark.com.au/pages/releaseview.action?pageId=9797728
 
One project to date has been developed using a co-operative model which allows greater than 20 investors but does not have as onerous upfront and ongoing costs as the company model above.
 
The current rules of the energy and financials market mean there are only two main viable business model for renewables – behind the meter solar, or large-scale wind or solar.  Community groups have developed models for both of these approaches, but it means that a mid-scale community solar farm or bioenergy projects are currently not cost effective, constraining what communities can do.  Particular challenges facing the economic viability of mid-scale renewables projects include:

• Difficulty negotiating a good PPA with a retailer;
• Cost of grid-connection;
• The high cost of using the grid, even if just transporting energy a short distance.  That is the lack of ability to do Local Energy Trading and the lack of a Local Generation Network Credit (see section below). 

 
Local Energy Trading
The current charging structure in the National Energy Market (NEM) reflects the historic model of one-way flows from large, remote generators, via the transmission and distribution systems, to the customer. Everyone except very large customers used all (or nearly all) network levels. This charging structure does not produce optimal outcomes. There is little incentive to reduce peak loads, there is no flexibility to cater for partial use of the distribution system, and the potential benefits of local energy generation and use are not rewarded.

Local generators sell at wholesale and buy back at retail prices.  Therefore, there is a strong incentive for these customers (and product developers) to focus “behind the meter” & reduce grid consumption. This again has the potential for increased costs for consumers left using only grid electricity, as infrastructure costs are recouped from smaller sales volume.

Local Electricity Trading or Virtual Net Metering involves an electricity customer with on-site generation assign their ‘exported’ electricity to other site(s). This requires netting off generation from one site at another site on a time-of-use basis, so that Site 1 can ‘sell’ or assign generation to nearby Site 2.   Local Electricity Trading provides an alternative to leaving the grid and provides social equity by mitigating the potential effect of spiralling customer loss from the network.

Benefits accrue to both the network and these local generators.  The network provides the local generators access to bigger markets, keeps a high level of reliability, allows local generator to run systems for maximum efficiency, and supports technical requirements of consumers.  In turn the local generators provides the networks with reduced transmission and distribution losses, the potential to save money on network investment, emissions reduction, increased resilience of system and technical network services.

Local Electricity Trading takes place between sites in the LV Distribution and potential HV Distribution and does not use Transmission and Subtransmission parts of the network.  However, the network charges for the full network are currently levied against those wishing to partake in Local Electricity Trading. These additional charges affect the potential financial viability of Local Electricity Trading.

Local Network Charges provide reduced tariffs for electricity generation used within a defined local network area. In most circumstances, the tariff would reduce the network charge portion of electricity bills for local generators to the extent that the generation reduces long term network costs. This recognises that the generator is using only part of the electricity network, and reduces the network charge accordingly.  To date reduced network tariffs have been applied most systematically in the UK. Local Network Charges should be technology neutral, calculated on performance rather than type of local generator, and applicable to range of sizes.

The introduction of reduced local network charges for partial use of the electricity network, and the implementation of local electricity trading between associated customers and generators in the same local distribution area provides a desirable alternative to customers who might otherwise choose to disconnect from the grid altogether or keep all their generation “behind the meter”, drastically reducing the amount of electricity they take from the grid.  

Reducing network charges for local energy is a proactive approach to keeping networks competitive and managing the transition to an electricity market with high contributions from local energy.  Local electricity trading coupled with local network charges has the potential to increase renewable energy options for the local community, supporting economic growth and local procurement of energy.

Further research and pilot projects are needed in a number of areas including project startup financing, legals, corporate governance and overheads, and investor models.


Save emissions and maximise the benefits in New South Wales - Reduce emissions in NSW to support achievement of interim and long term Commonwealth objectives
We oppose government support for research into low emissions coal technologies.  Supercritical black coal has approximately 2 ½ times the CO2 emissions of Combined cycle gas turbine and represents only a 8.5 % improvement on conventional coal thermal generation.

Further research, development and effort is required in the measurement and control of fugitive methane emissions.   For example one cannot base emissions levels for coal seam gas based on conservative US estimates from conventional gas extraction.  EPA should be conducting their own measurements or using a trusted third party.

We support the move to advocate for Commonwealth, COAG and international action consistent with the Paris agreement.
 
Government to lead by example to lower energy costs - Expand investment under the Government Resource Efficiency Policy
CLEANaS supports the initiative to support council to upgrade public lighting.  However, it should be noted that in NSW most councils do not own the public lighting as these are often owned by the electricity network and their use charged back to the local council.  LGA’s generally have little or no control over upgrades/replacements. It is proposed that a revised ownership/lease model be developed to allow for upgrades to be financed and carried out.

NSW government should look into the ACT funding model for energy efficiency undertaken with government departments which has a great deal of success.  This could be applied at a local government or state department level for NSW.
 
Reduce energy costs for households and businesses – Improve energy productivity for households and businesses
This needs to include a plan and actions to address energy efficiency in community based facilities.  Community groups often have significant energy costs which need to be funded out of community memberships and fundraising.  With energy efficiency measures identified and undertaken these funds can be redirected to core activities of the community groups.  Energy Efficiency measures such as lighting upgrades are cost effective with short payback periods using energy savings. 
 
Make homes more liveable and affordable for renters – Drive clean energy upgrades for rental households
We commend the NSW Government on making clean energy accessibility and affordability a focus of the Draft Strategic Plan.  This is a focus for many community energy groups in NSW.  We support the focus on renters including the plan to provide ratings for homes at the point of sale and lease and improve energy performances of tenanted houses.
To help drive clean energy upgrades in rentals, the NSW government should advocate tax changes to accelerate depreciation for energy  efficiency and Solar PV for investment properties.

Support vulnerable communities to access energy efficiency - Support vulnerable households to reduce their energy bills
Energy poverty is the unspoken issue with vulnerable communities and will only get worse as the effects of climate change impact on these communities.
In particular, we support the focus on social housing and looking at ways that concession schemes could be used to achieve lower bills and improved energy productivity/clean energy deployment.
The Home Power Saving Program delivered low-cost energy efficiency retrofits to over 220,000 low income households across NSW.  We propose to reinstate the Home Power Saving Program.
The Smart Energy Communities program outlined above has an important role in facilitating more innovative and complex clean energy models and programs for vulnerable and locked out energy users e.g. rates-based financing, rent-based financing, social access solar gardens etc
 
 
Other priorities
The raising of the Warragamba Dam wall has the potential to cause significant damage to world heritage-listed Greater Blue Mountains wilderness and national parks, by flooding 3,500 hectares.  In any case the Climate Change Fund should not be used to fund infrastructure projects.  Green bonds provide a mechanism for funding large green infrastructure projects that could be arranged through t-Corp.
 
Purpose of the fund
The purpose of the climate change fund is to reduce greenhouse gas emissions and the impacts of climate change, and to support water and energy savings. In the draft plan, the government is only consulting on $500m of the fund’s total $1.4bn over the next five years, while the bulk of the fund, $900m, is invested in projects, several of which are only tentatively linked to the purpose of the fund.
This plan proposes to support up to 540 MW of renewable energy projects over five years. By comparison, Victoria will contract an additional 1800 MW by 2020, and 5400 MW by 2025. ACT has already contracted 600 MW, 100% of their energy use by 2020.
NSW is already far behind other states when it comes to attracting renewable energy investment and jobs. Only 7.7% of the energy NSW generates comes from renewable sources, compared to SA’s 41%.
This draft plan proposes slashing government investment in renewable energy by 80% - from $214m in 2015 to $40m per year over the next 5 years (Climate Change Fund draft plan, page 10).
 http://www.environment.nsw.gov.au/grants/ccfund.htm

The NSW government shouldn’t reduce its investment in renewable energy. Instead, making greater use of the $1.4bn fund, as it was intended, it would make a substantial contribution to transitioning NSW to clean energy, and capturing opportunities such as jobs, innovation and investment. This is the type of effort that is required for NSW to act in line with the Paris agreement do its fair share to limit climate change to 1.5 to 2°C.

Orderly Transition
We welcome the fact that the NSW Government has recognised that an energy transition is underway and that an “orderly transition will deliver reliable, affordable energy into the future while avoiding bill shocks for households and businesses.”  In addition to an orderly transition, we call on the NSW Government to ensure that it is a just transition, particularly for communities and workers in coal regions of NSW.   Change is always difficult, but it becomes less so when those most affected by change are empowered to take control of their future.  Communities experiencing the shutdown of coal-fired power stations, need to be supported to develop comprehensive local economic plans and clean and renewable energy initiatives should be a component of these plans. 
 
Thank you for considering our submission,

Sincerely,

Alec Roberts
CLEANaS Chair
on behalf of CLEANaS